Jermaine Lee, Appellant-Defendant v. State of Indiana, Appellee-Plaintiff (2026)

MEMORANDUM DECISION

[1] Jermaine Lee challenges the revocation of his bond. But because the trial court has dismissed Lee's charges and released him from detention in this case, his appeal is moot. Therefore, we dismiss it.

Facts

[2] On July 16, 2025, the State charged Lee with Level 2 felony dealing in cocaine and Level 3 felony possession of cocaine. The same day, the trial court found probable cause and imposed a $100,000 surety bond. Lee posted bond in October 2025. But in April 2026, the State filed a motion to revoke Lee's bond, and Lee was detained when he appeared for a pretrial conference. Following a hearing the next month, the trial court revoked Lee's bond. Lee then filed this appeal.

Discussion and Decision

[3] Lee's briefing challenges both the admission of evidence at his bond revocation hearing and the sufficiency of the evidence to support the alleged violation of his bond conditions. We decline to address his arguments, however, because this appeal has become moot.

[4] An appeal becomes moot “when the appellate court cannot provide either party with effective relief.” J.F. v. St. Vincent Hosp. & Health Care Ctr., Inc., 256 N.E.3d 1260, 1264 (Ind. 2025). Here, the trial court's chronological case summary indicates it granted the State's motion to dismiss the charges against Lee on September 11 of this year. The trial court accordingly ordered Lee to be released from detention in this case. We take judicial notice of these proceedings. Ind. Evidence Rule 201(b)(5). Because Lee is no longer detained in this case, we cannot provide him with any effective relief through this appeal. It is, therefore, moot and subject to dismissal. Yeager v. State, 168 N.E.3d 277, 277 (Ind. 2021).¹

Conclusion

[5] We dismiss Lee's appeal on grounds of mootness.

FOOTNOTES

1.   Parties should inform an appellate court of a change in circumstances that might render a pending appeal moot. In re F.S., 53 N.E.3d 582, 591 (Ind. Ct. App. 2016).

Weissmann, Judge.

Bailey, J., and Brown, J., concur.